"Standing" | In 1972, the US Ninth Circuit Court of Appeals found that the Sierra Club Legal Defense Fund had no standing to protect the Mineral King Valley from development because the valley itself had no rights. The case was appealed to the Supreme Court. Sierra Club v. Morton, 405 U.S. 727 (1972) is perhaps best known for the dissenting opinion by Justice William O. Douglas who asserted that natural resources ought to have standing to sue for their own protection. An excerpt from his dissent:

The critical question of "standing" would be simplified and also put neatly in focus if we fashioned a federal rule that allowed environmental issues to be litigated before federal agencies or federal courts in the name of the inanimate object about to be despoiled, defaced, or invaded by roads and bulldozers and where injury is the subject of public outrage. Contemporary public concern for protecting nature's ecological equilibrium should lead to the conferral of standing upon environmental objects to sue for their own preservation. This suit would therefore be more properly labeled as Mineral King v. Morton.